AVP - KYC
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Ensures that the KYC activities for non-individual and individuals and process are performed in full compliance with French and European banking laws, as well as Group and local policies and procedures, and remain up to date with any regulatory or internal changes.
The KYC AVP will perform independent reviews of KYC files at the time of client on-boarding, trigger base and KYC periodic reviews.
The KYC AVP will perform the Customer Due-Diligence following the AML-CFT Risk Rating and ensure that the KYC files are complete in terms of required KYC information / documentation in accordance with bank’s policies / procedures and local regulatory expectations, while ensuring that AML / CTF / Sanctions risks associated with the clients are appropriately identified, assessed and mitigated before a decision is taken to on board or retain bank clients and the Group CDD standards are adhered and enforced.
KEY RESPONSIBILITIES
Business As Usual
- Manage the day-to-day KYC analyst activities of reviewing KYC files and performing all required checks and controls to ensure completeness and readiness of the file for final review and approval.
- Conduct end to end required Customer Due-Diligence measures, for New to bank onboarding, trigger events or periodic reviews and vendors.
- Perform manual screening for PEP detection, sanctions, asset freeze and adverse media/negative news.
- Verify account opening forms are duly completed adequately.
- Review AML and Sanctions Questionnaires, where applicable.
- Perform Customer Risk Assessment including risk scoring and justification where applicable.
- Ensure appropriate checks and controls within the team to ensure files are processed correctly.
- Ensure compliance with local regulations and FAB bank policies/ procedures related to CDD, AML/CTF, PEPs and Sanctions.
- Ensure CDD/EDD information and documentation are complete, up-to-date and compliant with bank policies, procedures and local regulatory requirements.
- Ensure compliance with GCDD, local SOPs, dedicated checklists and process notes.
- Always ensure adherence to all internal policies / procedures and external regulatory requirements.
- Prepare detailed Customer Due Diligence Control sheet, Financial Crime referral forms and deviation justification where applicable.
- Prepare and maintain KYC documentation in line with Bank GCDD and local process.
- The KYC AVP shall assist the Head of Middle-Office:
- to the continuous improvement of KYC processes, controls, and documentation, including feedback following audits or reviews and the implementation of corrective actions for issues/challenges identified.
- Promote a culture of quality, risk awareness and compliance within the KYC team.
- Analyze the information and documentation provided with the customer profile, with particular attention to revenues and wealth, ensuring that all materials and data are relevant and accurate.
- Verify the authenticity of documents to confirm they are not fraudulent or falsified.
Process, Governance & Controls
- Ensure KYC processes, procedures, and controls remain up to date in line with regulatory developments, internal policy updates, and Group instructions.
- Escalate identified gaps, inconsistencies, high-risk cases, or control weaknesses to Compliance in a timely manner.
- Prioritization – maintain the discipline in partnership with the local business. Communicate consistency to internal and external stakeholders to ensure that the KYC cases are accepted through the approved channels and expectations are managed appropriately.
- Follow defined RCSA requirements and identify, document and escrow relevant KRIs (where applicable).
- Perform maker reviews and send the file for approval to Head of Middle Office.
- Ensure that 100% of files receive a Quality Control review prior to sign-off, as applicable.
Key Accountabilities in a Hub Operating Model
- Oversee the execution and coordination of KYC activities delivered through the HO/Hub model, covering New-to-Bank onboarding, Periodic Reviews, Trigger Reviews, and related customer/account data maintenance activities, ensuring alignment with FAB France procedures, local regulatory requirements, Group standards, and agreed service expectations.
- Monitor Hub performance, case progression, service levels, productivity, volumes, pending items, and escalations, ensuring timely follow-up with the Hub, Business, Compliance, and other France stakeholders.
- Provide operational oversight, guidance, training inputs, and process clarifications to the Hub, including updates on regulatory expectations, internal policies, procedures, system parameters, and local process requirements.
- Manage and support escalation handling for operational issues, high-risk matters, non-